SmartAlex Switzerland Data Protection Notice (nFADP)
1. Purpose and scope
THERCSGROUP PTE. LTD., trading as SmartAlex ("SmartAlex", "we", "us", "our"), operates the SmartAlex platform, websites, applications, and APIs (the "Services").
This Switzerland Data Protection Notice (the "Notice") is a Switzerland overlay. It explains how the Swiss data protection framework applies to our processing of personal data relating to individuals in Switzerland. It supplements, and does not replace, our Privacy Policy and our GDPR Article 13 Notice. Where there is any inconsistency on a Swiss-specific point, this Notice governs for individuals in Switzerland; on all other matters the Privacy Policy and the GDPR Article 13 Notice continue to apply.
Defined terms used but not defined here have the meaning given to them in the Privacy Policy or, where relevant, in our Data Processing Addendum.
2. The nFADP
The revised Swiss Federal Act on Data Protection (the "nFADP", also referred to as the revFADP) applies to the processing of personal data of people in Switzerland. The nFADP is broadly aligned with the EU General Data Protection Regulation (the "GDPR") but contains Swiss-specific features, including its own terminology, its treatment of data on legal entities in some contexts, its categories of sensitive personal data, and its own supervisory authority and enforcement regime.
Where our processing falls within the scope of the nFADP, this Notice explains the Swiss position. Where our processing also falls within the scope of the GDPR, the GDPR Article 13 Notice continues to apply alongside this Notice.
3. Data we process and why
We process personal data to provide, secure, support, and improve the Services, to communicate with users, to meet legal and regulatory obligations, and for the other purposes described in our documentation. The categories of personal data we process, the sources of that data, the purposes of processing, and the legal grounds we rely on are set out in detail in the Privacy Policy and the GDPR Article 13 Notice.
For individuals in Switzerland, those descriptions apply on a Swiss basis and should be read consistently with the nFADP. We keep the same detail in a single place so that it stays accurate and current, rather than restating it here.
3.1 Service providers
We use a limited number of service providers to help us deliver the Services. The current list, together with the function each performs, is maintained in our Subprocessor List.
4. Your rights
Subject to the conditions and exceptions in the nFADP, individuals in Switzerland have the following rights in relation to their personal data:
- Access: to obtain confirmation of whether we process personal data about you, and to receive information about that processing.
- Rectification: to have inaccurate or incomplete personal data corrected.
- Deletion: to request deletion or destruction of your personal data where the conditions for that request are met.
- Objection: to object to certain processing of your personal data.
- Data portability: to receive personal data you have provided to us, and in certain cases to have it transferred, in a commonly used electronic format.
- The right to receive information: to be informed about the collection and processing of your personal data, as set out in this Notice and the documents it references.
To exercise any of these rights, contact us at privacy@getsmartalex.com. We may need to verify your identity before responding, and some requests may be subject to limits or exceptions permitted under the nFADP. If we act as a processor on behalf of a customer, we will refer your request to the relevant customer as the controller, or handle it in accordance with our agreement with that customer.
5. Swiss representative
In certain cases the nFADP requires a controller with no establishment in Switzerland to designate a representative in Switzerland, for example where it carries out large-scale, high-risk processing of personal data of individuals in Switzerland in connection with offering goods or services or monitoring behaviour.
Where that requirement applies to our processing, SmartAlex will designate a representative in Switzerland and publish the representative's details in this Notice. As at the effective date of this Notice, we do not name a Swiss representative here, and nothing in this section should be read as a representation that one is currently designated. For the general approach we take to appointing and publishing representatives, see our EU and UK Representative Notice.
6. International transfers
We are a Singapore company and our service providers are located in a number of countries. As a result, personal data collected in Switzerland may be transferred to Singapore and to other jurisdictions.
Where we transfer personal data out of Switzerland, we do so using recognized safeguards and, where applicable, under the terms of our Data Processing Addendum. The Swiss authorities recognize certain transfer mechanisms, including transfers to countries assessed as providing adequate protection and transfers made under approved contractual safeguards. Further detail on transfers and safeguards is set out in the Privacy Policy and the GDPR Article 13 Notice, and the recipients of personal data are described in the Subprocessor List.
7. Automated decision-making
The Services use artificial intelligence to process conversations and related data. Consistent with our position on the responsible use of AI, we do not make decisions that produce legal effects concerning you, or that similarly significantly affect you, based solely on automated processing without appropriate safeguards. Where automated processing of that kind takes place, we apply safeguards such as meaningful information about the logic involved and the ability to obtain human review, in line with the nFADP. Where SmartAlex acts as a processor, the customer as controller is responsible for the decisions it makes using the Services.
8. Complaints
If you have concerns about how your personal data is handled, we encourage you to contact us first at privacy@getsmartalex.com so that we can try to resolve the matter. Individuals in Switzerland may also contact the Swiss Federal Data Protection and Information Commissioner (the "FDPIC"), which is the supervisory authority for data protection in Switzerland.
9. Relationship to other documents
This Notice should be read together with the following documents, which contain the underlying detail it draws on:
- Privacy Policy
- GDPR Article 13 Notice
- Data Processing Addendum
- EU and UK Representative Notice
- Subprocessor List
This Notice addresses Swiss-specific points only. On all other matters, the documents listed above continue to apply.
10. Updates and contact
We may update this Notice from time to time to reflect changes in the Services, our processing, or applicable law. When we make material changes, we will revise the version and effective date below and, where appropriate, provide additional notice.
For any questions about this Notice or about how we handle personal data, contact us at privacy@getsmartalex.com or legal@getsmartalex.com. Individuals in Switzerland may also contact the Swiss Federal Data Protection and Information Commissioner (FDPIC).
This Notice is issued by THERCSGROUP PTE. LTD. (UEN 202543608D), 160 Robinson Road, #14-04 Singapore Business Federation Center, Singapore 068914, and is governed by the laws of the Republic of Singapore.
11. Version and effective date
This Switzerland Data Protection Notice is version 1.0 and is effective from 8 July 2026.